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Contrary to these assertions, there is no evidence in
the record to suggest that Motion, Inc.'s line of credit
and security agreement had anything to do with petitioner
in his individual capacity, as opposed to his capacity as
corporate officer of Motion, Inc. There is also no
evidence to suggest that Motion, Inc., was not a validly
existing corporation and thus a separate entity from
petitioner. In fact, petitioner's opening brief refers to
Motion, Inc., as "a wholly owned corporation of Petitioner,
Ronald Bradshaw", and petitioners' reply brief refers to it
as "Petitioner's wholly owned corporation, Motion, Inc."
Colonial Bank's original petition, by which it
initiated suit against petitioner and Motion, Inc., does
not suggest that the proceeds of petitioner's check-kiting
scheme had been obtained through a bona fide indebtedness.
To the contrary, the principal claim in the original
complaint was a "CLAIM FOR REIMBURSEMENT" under which
Colonial Bank sought to hold petitioner and Motion, Inc.,
liable based upon the fact that petitioner had deposited
into his account at Colonial Bank worthless checks drawn on
the account of Motion, Inc., in Tarrant Bank, and the fact
that Colonial Bank was a holder in due course with respect
to each of those checks. The original petition also sought
to foreclose its security interest in assets owned by or
due to Motion, Inc., and to obtain any proceeds that had
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